Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
An alleged breach of natural justice was rejected because the Adjudicating Authority had only permitted a short note on maintainability at the first listing and had not called for a full reply to the Section 9 application. On the merits, the Tribunal held that the reply and rejoinder disclosed a plausible pre-existing dispute over reconciliation and settlement of contractual dues, including assertions that dues stood paid or adjusted, credit notes were issued, and nothing further remained payable. Applying Mobilox and Sabarmati Gas, it held that Section 9 cannot be used to resolve such contractual controversies and upheld rejection of the insolvency application.
An alleged breach of natural justice was rejected because the Adjudicating Authority had only permitted a short note on maintainability at the first listing and had not called for a full reply to the Section 9 application. On the merits, the Tribunal held that the reply and rejoinder disclosed a plausible pre-existing dispute over reconciliation and settlement of contractual dues, including assertions that dues stood paid or adjusted, credit notes were issued, and nothing further remained payable. Applying Mobilox and Sabarmati Gas, it held that Section 9 cannot be used to resolve such contractual controversies and upheld rejection of the insolvency application.
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